The country of origin of an idler assembly

N344520 December 23, 2024 OT:RR:NC:N1:103 CATEGORY: Origin Riccardo Giorgi Beyond Bounds S.r.l. Strada Repubblica, 31Parma 43121Italy RE:  The country of origin of an idler assembly Dear Mr. Giorgi: In your letter dated December 9, 2024, you requested a country of origin ruling on an idler assembly on behalf if your client, ITR America LLC. The subject merchandise, also referred to as an idler, part number UI056, is described as a component used within the track assembly of the undercarriage in a Caterpillar bulldozer. The assembly consists of a shell, shaft, collars, pins, retainers, seals, and more. The subject idler is completed in China using components sourced from Vietnam and China. The idler shell (also referred to as an idler wheel) is cast in Vietnam, a process that entails pouring molten metal alloy into a sand mold. When the shell is exported from Vietnam, it has the form of an idler, that is, two external radial supports, a central raised section, its center hole, and so forth. Based on your description, the raised section is used to drive the track as it slides on the radial supports. In China, the shell is finished prior to final assembly. The steps involve removing a small percentage of material by machining the casting to its final tolerances and then hardening the external surface of the shell using a heat treatment. The idler shell is then assembled with the remaining components sourced from China, including a shaft, collar, retainer, bush, plug, pins, seals, O-rings, bolts, and washers. Lastly the assembly is painted and packaged for export. You requested a ruling regarding the country of origin of the idler for the purposes of determining the applicability of measures imposed under Section 301. When determining the country of origin for purposes of applying current trade remedies under Section 301, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In viewing the information provided with your submission, the idler shell is the component that mainly defines the assembly and has a pre-determined end use prior to being subjected to the described finishing processes in China. It is not substantially changed by the addition of the remaining components, nor are the finishing and assembly operations complex enough to transform the idler into a new article. When exported from Vietnam, the idler, while not ready for direct use, has the approximate shape and outline of finished idler, and can only be used as such upon completion. Therefore, the country of origin of the idler assembly, part number UI056, is Vietnam for the purpose of Section 301 Trade Remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division